# R4 — Market, Demand & Competition Research
## New small NDIS provider in Victoria — three candidate service models
Prepared: 2026-08-20 | Class: STANDARD | REQ-SYS-04, REQ-SYS-07, REQ-CON-01, REQ-CON-02

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## 1. SIZE

**National:** 774,456 active participants with approved plans as at 31 March 2026 (Q3 2025-26 Quarterly Report), a 1.7% increase on the December 2025 quarter. [R4-01]

**Victoria:** 199,577 active participants with approved plans as at 30 June 2025 (most recent Victoria-specific NDIA dashboard located; net quarterly growth +6,604 in that quarter). No later state-disaggregated participant count could be located — the Q3 2025-26 national report states state/territory comparisons are moving to six-monthly reporting from Q4 2025-26, which may explain the gap. [R4-02] **[PARTIALLY UNVERIFIED — Victoria figure is ~9 months older than the national headline figure; treat as indicative, not current.]**

**Growth rate:** Scheme grew 5% in the 12 months to June 2026 nationally, against an 8% policy target; scheme expense growth was 11.3% for the 12 months to March 2026 (cost growth is running well ahead of participant-number growth, implying rising average package size and/or price/utilisation growth). [R4-01] [R4-03]

**Average annualised plan budget:** National: no single official "average plan" figure could be located; a derived estimate from quarterly payments (~$12.4bn/quarter ÷ participants) is ~$64,000/participant/year, but this is a third-party calculation, not an NDIA-published figure — treat as indicative. [R4-04] Victoria (as at 30 June 2025, NDIA-published): average annualised plan budget $76,000 for active participants; $479,800 for participants in Supported Independent Living (SIL); $59,500 for those not in SIL. [R4-02]

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## 2. SUPPLY

**Active providers (national):** 277,376 as at the Q3 2025-26 reporting period, per NDIA quarterly data referenced in a third-party statistics summary; this is "active" (paid in the quarter), not "registered," and the large majority of active providers are **unregistered**. [R4-04] A separate industry report (2025) cites "269,000+ providers" serving "739,000+ participants" with no single provider holding >5% market share nationally — indicating an extremely fragmented, low-concentration market. [R4-05] **These two provider counts come from different snapshots/definitions and could not be cross-verified against the primary NDIA provider dataset (the raw CSV was not accessible via fetch) — confidence Medium.**

**Victoria-specific provider/registration counts:** **UNVERIFIED** — could not locate an authoritative, dated count of registered or active providers specific to Victoria within the tool budget for this task. The NDIS provider datasets page (dataresearch.ndis.gov.au) confirms Victoria-level active-provider data exists as a downloadable CSV as at 30 June 2026 but the count itself was not extractable via fetch. [R4-06]

**Over/under-supply signal for core supports, metro Melbourne:** No authoritative, quantified statement of over- or under-supply specific to metropolitan Melbourne core supports was found. Indirect evidence points both ways: (a) national fragmentation and low market share per provider suggest low barriers/many competitors in populated areas [R4-05]; (b) NDS sector survey data shows 77% of providers report turning away people needing support due to capacity/funding constraints, which is more consistent with constrained supply of *viable* provision than oversupply [R4-07]. **Net: UNVERIFIED / mixed signals — no single reliable source states Melbourne core supports as "oversupplied" or "undersupplied."**

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## 3. PROVIDER FINANCIAL HEALTH

NDS *State of the Disability Sector Report 2025* (via secondary summary; primary NDS report page located but full PDF/statistics not extractable via fetch): **nearly half of disability service providers reported a financial loss in 2024–25**; **81% say they cannot continue delivering services at current NDIS prices**; 77% delivered unpaid/unfunded supports in the past year, averaging >$460,000 per organisation (>$69m sector-wide); 77% are turning away people needing support due to capacity/funding constraints. [R4-07] Confidence: Medium — sourced via a secondary summary of the NDS report, not the primary NDS PDF itself.

Ability Roundtable benchmarking (National Disability Services industry partner; white paper originally August 2023, updated April 2024, referencing FY2021-22/2022-23 data and forward modelling into FY2023-24): 68% of benchmarked providers reported losses in FY2021-22; 64% in H1 FY2022-23; median loss 2.6%; most profitable providers achieved only 1–1.5% margins vs the NDIA's ~2% price-model target; workers' compensation costs for ~87% of providers exceeded the NDIA cost-model assumption of 1.7%; forward modelling predicted >76% of benchmarked providers operating at a loss by end of FY2023-24, with >50% facing three consecutive loss years. [R4-08] Confidence Medium — data is 2–3 years old relative to August 2026 "now," sourced via a secondary explainer rather than the primary Ability Roundtable PDF.

**Named market exits cited (2025):** Centacare Queensland (~700 clients, ~600 staff affected), Bedford Group (voluntary administration), NDISP (SDA-specialist provider closure). [R4-07] These are illustrative examples, not a systematic insolvency-rate statistic — no ASIC-sourced sector insolvency rate was located. **UNVERIFIED: aggregate insolvency/exit rate for the NDIS provider sector.**

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## 4. GROWTH CONTROL

National Cabinet's target is 8% annual scheme growth by 1 July 2026, down from a trajectory that reached as high as 23%/year under prior settings. [R4-03] Actual result: the scheme grew 5% in the 12 months to June 2026 — i.e. growth in *participant numbers* is currently running **below** the 8% target — while scheme *expense* growth was 11.3% for the 12 months to March 2026, indicating cost per participant/package growth is the live pressure, not headcount growth. [R4-01] [R4-03] Measures cited as in force: clarified funding-scope rules (what NDIS funding can/cannot be used for), enhanced planning/decision consistency, proactive contact with participants at risk of plan exhaustion, continued "Crack Down on Fraud" payment-integrity program, and plan-cost stabilisation measures — reforms collectively projected (NDIA/DSS communications) to reduce scheme cost growth by $19bn over four years. [R4-03] Confidence Medium — this synthesis is drawn from an NDIA news article rather than the primary Annual Financial Sustainability Report, which was located but not fetched in full within the tool budget.

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## 5. FOUNDATIONAL SUPPORTS

Status as at August 2026: the **National Agreement on Foundational Supports 2026–2031** has been signed (dated March 2026). [R4-09] The first tranche, **"Thriving Kids,"** targets children aged 8 and under with developmental delay and/or autism with low-to-moderate support needs, backed by $4bn over 5 years in joint Commonwealth/state funding, scheduled to commence **1 October 2026** with full rollout by January 2028. [R4-10] [R4-11] As at 16 August 2026: Minister Jenny McAllister said she was "confident" of an on-schedule October launch but **Queensland has refused to participate**, and she explicitly declined to commit to delaying access changes if alternative (foundational) supports are not ready ("We are not contemplating delay at this point"). [R4-11] The government's own projection is that **~300,000 people are expected to be removed from, or prevented from accessing, the NDIS**, with this effect projected around 2028. [R4-11] State/territory ministers and Senate inquiry witnesses have warned alternative services will not be ready in time, and have flagged a specific risk of children "ageing out" of Thriving Kids (limited to 8-and-under) without continuing support. [R4-11]

**Effect on demand for core supports:** Directionally, foundational supports/Thriving Kids is designed to shift a cohort of *low-to-moderate-needs* children out of the NDIS and into a separate, non-NDIS-funded support system from October 2026, which would reduce the pool of NDIS-funded core-supports demand for that specific cohort over time — but implementation risk (Queensland non-participation, readiness concerns, no confirmed delay mechanism) means the actual near-term (FY2026-27) effect on core-supports demand is **UNVERIFIED / not yet quantified in any source found**.

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## 6. SUPPORT COORDINATION → "NAVIGATORS"

The NDIS Review Final Report (December 2023) recommended replacing support coordination with a "navigator" model, to be funded outside participant plans rather than from within them. [R4-12] Status as at (article dated) March 2026: support coordination **has not been phased out** and continues operating normally; the navigator model remains a recommendation under a proposed five-year implementation period, not yet implemented policy. Cited timeline: 2024–2025 consultation/design work with ~$20m allocated for preliminary development; mid-2026 onward, framework planning; 2026–2028 co-design, piloting and gradual rollout. A joint DANA/NDS report, *"Guiding the Way: Building Common Principles for Navigators"* (April 2025), and a $45m Quality Supports Program are cited as concrete artefacts of this process. Most current coordinators are expected to be able to transition into navigator roles with additional training when/if implemented. [R4-12] Confidence Medium — sourced from a single secondary explainer site, not the NDIS Review report or NDIA policy page directly; the underlying claims (funding figures, program names) were not independently cross-checked against a primary government source within the tool budget.

**Risk assessment for a new provider entering support coordination in 2026:** the service line is **not imminently being removed**, but it is under an active, government-endorsed structural-change process with a multi-year horizon (through ~2028) and an explicit design intention to change its funding mechanism — this is a material medium-term regulatory-risk factor for anyone building a business predominantly around fee-for-service support coordination now.

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## 7. PLAN MANAGEMENT

No authoritative, quantified data on plan-management market concentration (e.g. top-N providers' share) was located. A 2026 explainer piece flags that consolidation *may* be occurring ("data suggests... there may be shifts in how many plan managers operate") but supplies no figures, and separately anticipates increased algorithmic/digital involvement in planning by mid-2026, tightening compliance requirements, and growing emphasis on financial transparency as a competitive differentiator. [R4-13] **UNVERIFIED: no primary source found for plan-management market share, HHI, or provider-count trend; no confirmed formal policy change to plan management itself (as distinct from planning processes generally) was found.** Confidence Low on this whole question — findings rest on a single non-primary source with no cited figures.

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## 8. SIL / SDA

**SDA supply/demand (national, Q1 2026, per a specialist SDA-data analytics site, paywalled beyond the summary level):** 25,633 total eligible SDA participants vs 30,271 total SDA places nationally — a headline national surplus of +4,638 places and a 53.7% utilisation rate. The source notes utilisation is uneven regionally (some states show "shortfall/opportunity," others "surplus/caution"), so a national surplus does not mean Melbourne/Victoria specifically is oversupplied — this was not disaggregated to Victoria within the tool budget. [R4-14] Design-category-level breakdown and formal vacancy rates sit behind that site's paywall and could not be extracted — **UNVERIFIED at the design-category level.**

**SIL scale (Victoria, 30 June 2025 NDIA dashboard):** average annualised budget for SIL participants was $479,800 vs $59,500 for non-SIL participants — indicating SIL packages are roughly 8x the size of a typical non-SIL package, consistent with SIL requiring materially larger scale/rostering/property infrastructure to operate viably. [R4-02] Nationally (per third-party statistics summary of NDIA data), 36,808 participants received SIL, with SIL payments of ~$16.4bn/year (~$4.1bn/quarter). [R4-04]

**Compliance intensity:** NDS published guidance ("Looking ahead at SIL and SDA compliance and registration") was identified confirming that SIL/SDA sits under active, tightening compliance and registration attention, but the specific content of that guidance was not fetched within the tool budget — **UNVERIFIED in detail; flagged for follow-up if SIL/SDA is shortlisted.**

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## 9. ENTRY BARRIERS / FIRST-CLIENT PATHWAYS

A practitioner article on referral-generation for new NDIS providers identifies **Support Coordinators as the primary gatekeeper** for first clients: "Support Coordinators will often send out multiple referrals at once. The provider who gets back first usually wins." Success factors cited: minimal-friction referral/intake process ("no six-page referral forms, no PDF downloads"), fast response times, and ongoing communication with the coordinator to avoid referrals "going cold." The author's own first referral came via a personal/professional relationship with a support coordinator (a niche capability — Auslan fluency — matched to a specific participant need). [R4-15] Confidence Low–Medium — single practitioner blog post, anecdotal rather than data-driven. **No quantified data on typical time-to-first-client, and no detail on plan managers' or provider-finder listings' role in referrals, was found — UNVERIFIED for those two sub-questions.**

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## 10. FAILURE MODES

The clearest sourced analysis is the Ability Roundtable / Team DSC synthesis (see §3): it attributes provider financial distress to (a) the NDIA's Disability Support Worker Cost Model being calibrated to viability for only the top ~25% of organisations by design; (b) uncontrollable external cost pressures (inflation, NDIA billing/system changes, NDIS Commission compliance obligations, insurance); (c) a persistent gap between modelled and actual wage costs (workers paid ~$1/hour above the model on average over three years); and (d) workers' compensation premiums exceeding the cost-model assumption for the large majority (~87%) of benchmarked providers. [R4-08] The NDS State of the Disability Sector Report data (§3) adds that unfunded/unpaid service delivery (77% of providers, >$460k/organisation on average) is a further structural drain not captured in headline pricing. [R4-07] Both sources are sector-wide, not specific to *new small* providers, and neither is a formal cause-of-insolvency dataset (e.g. ASIC) — **UNVERIFIED: no ASIC or other registrar-level insolvency-cause dataset specific to NDIS providers was located.**

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## MODEL COMPARISON TABLE

| Service model | Market size signal | Competitive intensity | Regulatory risk in 2026 | Capital intensity | Time to first revenue | Key published risk | Source URLs |
|---|---|---|---|---|---|---|---|
| **(a) Core supports** (personal care & community participation) | Largest addressable base: majority of ~774,456 national / ~199,577 Victorian active participants use some core supports; average non-SIL VIC package ~$59,500/yr [R4-01][R4-02] | High fragmentation, low concentration (269,000+ providers, no provider >5% share nationally) [R4-05]; entry gated mainly by support-coordinator relationships, not registration [R4-15] | Moderate — not a named target of NDIS Review structural change, but exposed to (i) foundational-supports cohort shift potentially removing some low/moderate-needs demand from FY26-27 [R4-11], and (ii) general price/compliance tightening [R4-03] | Low–moderate — no property/SIL infrastructure required; workforce is main cost driver | Fastest of the three, per practitioner accounts, once a support-coordinator referral relationship is established — but no quantified benchmark found [R4-15] | Sector-wide margin compression: ~half of providers loss-making in 2024-25; median historical loss 2.6%, target margin only ~2% [R4-07][R4-08] | ndis.gov.au/media/8641/download; ndis.gov.au/media/7844/download; caremaster.com.au (NDS report summary); teamdsc.com.au |
| **(b) Support coordination + plan management** | Support coordination demand tied to plan numbers; plan management market size/concentration data not found (UNVERIFIED §7) | Support coordination entry appears accessible (same referral dynamics as (a)); plan management concentration unknown — UNVERIFIED | **Highest of the three** — support coordination is subject to an active, government-endorsed multi-year "navigator" restructuring process (NDIS Review Dec 2023 recommendation; design/pilot through 2026-2028, funding mechanism intended to change) [R4-12]; plan management facing anticipated digitisation/tightening compliance with no confirmed formal policy yet [R4-13] | Low — professional/admin service, no fixed infrastructure | Likely fast for support coordination (same referral-network dynamic); not established for plan management | Structural redesign of support coordination during the life of a new business; navigator transition could change how the service is funded/delivered within a ~5-year horizon [R4-12] | centreofhope.com.au (navigators); inkl.com (plan management); ndisreview.gov.au (NDIS Review) |
| **(c) SIL / SDA supported accommodation** | National SDA: 25,633 eligible participants vs 30,271 places, national surplus +4,638 (53.7% utilisation) — but regionally uneven, Victoria/Melbourne not disaggregated (UNVERIFIED at that level) [R4-14]; SIL packages ~8x the size of non-SIL packages in Victoria (~$479,800 vs ~$59,500/yr) [R4-02] | Concentrated toward larger/scaled operators given rostering and property requirements; national SIL participants ~36,808 with ~$16.4bn/yr in payments [R4-04] | Increasing — NDS flags active/tightening SIL and SDA compliance and registration attention (detail UNVERIFIED — not fetched) [R4-16] | **Highest of the three** — property (SDA) and 24/7 rostered workforce (SIL) infrastructure; largest packages of any support type in VIC data | Slowest — property acquisition/fit-out (SDA) and building a rostered SIL workforce before first tenancy/service start are inherent lead-time items; no quantified benchmark found | National-level SDA surplus/low utilisation (53.7%) signals possible localised oversupply risk; high compliance intensity flagged by NDS [R4-14][R4-16] | sdasignals.com.au/sda; nds.org.au/news/looking-ahead-at-sil-and-sda-compliance-and-registration (not fully fetched) |

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## SOURCES TABLE

| Claim ID | Claim | Value | URL | Publisher | Source date | Accessed | Confidence | Why below High |
|---|---|---|---|---|---|---|---|---|
| R4-01 | National active participants; growth; expense growth | 774,456 participants (31 Mar 2026, +1.7% QoQ); scheme grew 5% in 12 months to Jun 2026; expenses +11.3% (12 months to Mar 2026) | https://www.ndis.gov.au/media/8641/download | NDIA (Quarterly Report Q3 2025-26) | ~May 2026 | 2026-08-20 | High | Primary NDIA report, directly fetched |
| R4-02 | Victoria participants, growth, avg budgets | 199,577 active participants (30 Jun 2025); +6,604 in quarter; avg budget $76,000 (SIL $479,800 / non-SIL $59,500) | https://ndis.gov.au/media/7844/download?attachment= | NDIA (Victoria Quarterly Performance Dashboard) | 30 Jun 2025 | 2026-08-20 | Medium | Most recent Victoria-specific figure found is ~14 months old vs the national Mar-2026 figure — not contemporaneous |
| R4-03 | 8% growth target; measures to constrain growth | Target 8% by 1 Jul 2026 (down from up to 23%/yr); 5-point reform program; ~$19bn/4yr projected saving | https://www.ndis.gov.au/news/10531-ndis-growth-target-track-be-delivered | NDIA news | undated (2026) | 2026-08-20 | Medium | NDIA news article summarising the Annual Financial Sustainability Report, not the primary report itself |
| R4-04 | Active providers; SIL participants/spend; derived avg budget | 277,376 active providers; 36,808 SIL participants; ~$16.4bn/yr SIL payments; ~$64,000 derived avg budget | https://ndisgrowth.com.au/ndis-statistics/ | ndisgrowth.com.au (third-party, cites NDIA Q3 2025-26) | page updated 12 Aug 2026 | 2026-08-20 | Medium | Secondary aggregator site, not the primary NDIA dataset; "average budget" explicitly flagged by the source itself as a derived, not official, figure |
| R4-05 | Provider fragmentation / market share | 269,000+ providers, 739,000+ participants, no provider >5% share; target margin ≤2.0% | https://vccg.com.au/state-ndis-provider-market-2025-industry-report/ | VCCG (industry consultancy market report) | 2025 | 2026-08-20 | Medium | Industry consultancy report, not government primary source; provider count differs from R4-04's 277,376, definitions not reconciled |
| R4-06 | Provider datasets exist by state incl. Victoria | Active providers CSV as at 30 Jun 2026, by state/territory | https://dataresearch.ndis.gov.au/datasets/provider-datasets | NDIA data & research | as at 30 Jun 2026 | 2026-08-20 | Medium | Confirms data exists but numeric values inside the CSV were not extractable via fetch |
| R4-07 | Provider losses, unfunded supports, capacity turn-aways | ~50% loss-making 2024-25; 81% say can't continue at current prices; 77% deliver unpaid supports (>$460k/org avg); 77% turning away clients | https://caremaster.com.au/post/the-state-of-the-disability-sector-report-2025---the-real-risk-were-not-talking-about | Caremaster (secondary summary of NDS State of the Disability Sector Report 2025) | 2025 | 2026-08-20 | Medium | Secondary summary; primary NDS report page (nds.org.au) located but full report content not extractable via fetch |
| R4-08 | Historical provider loss rates & cost-model gap | 68% loss-making FY21-22; 64% H1 FY22-23; median loss 2.6%; best margins 1-1.5%; 87% workers' comp above model | https://teamdsc.com.au/resources/are-service-providers-in-trouble/ | Team DSC, citing Ability Roundtable white paper | updated 15 Apr 2024 (orig. 15 Aug 2023) | 2026-08-20 | Medium | Data is FY21-22/22-23, i.e. 2-3+ years old relative to Aug 2026; secondary source, not the primary Ability Roundtable PDF |
| R4-09 | National Agreement on Foundational Supports signed | Agreement covering 2026-2031 | https://federalfinancialrelations.gov.au/sites/federalfinancialrelations.gov.au/files/2026-03/nafs-signed.pdf | Federal Financial Relations (Commonwealth/state agreement) | Mar 2026 | 2026-08-20 | High | Primary signed intergovernmental document (title/date only reviewed, not fetched in full) |
| R4-10 | Thriving Kids scope and funding | Children 8 & under, developmental delay/autism, low-moderate needs; $4bn/5yr; commences 1 Oct 2026, full rollout Jan 2028 | https://www.ndis.gov.au/media/8641/download | NDIA (Quarterly Report Q3 2025-26) | ~May 2026 | 2026-08-20 | High | Primary NDIA report |
| R4-11 | Thriving Kids status, QLD non-participation, ~300,000 affected | Minister "confident" of Oct 2026 launch; QLD opted out; ~300,000 removed/prevented from NDIS access (~2028); no delay commitment | https://www.abc.net.au/news/2026-08-16/ndis-cuts-delay-thriving-kids-jenny-mcallister/107043264 | ABC News | 2026-08-16 | 2026-08-20 | High | Reputable mainstream news source, directly fetched, dated within the current week |
| R4-12 | Navigator model status and timeline | Not yet implemented; design/pilot 2026-2028; $20m prelim funding; $45m Quality Supports Program; DANA/NDS joint report Apr 2025 | https://centreofhope.com.au/ndis-navigators-future-of-support-coordination/ | Centre of Hope (sector explainer site) | dated "as of March 2026" | 2026-08-20 | Medium | Single secondary explainer, not the NDIS Review report or an NDIA/DSS primary policy page; figures not independently cross-checked |
| R4-13 | Plan management market outlook | Possible consolidation (unquantified); algorithmic planning, tightening compliance anticipated by mid-2026 | https://www.inkl.com/news/ndis-plan-management-in-2026-navigating-change-and-maximising-choice | inkl (news aggregator/explainer) | 2026 | 2026-08-20 | Low | No concrete figures given; source itself states uncertainty rather than fact |
| R4-14 | SDA national supply/demand | 25,633 eligible participants vs 30,271 places; +4,638 surplus; 53.7% utilisation (Q1 2026) | https://sdasignals.com.au/sda | SDA Signals (specialist analytics site) | Q1 2026 (released 2026-03-31) | 2026-08-20 | Medium | Commercial analytics site; underlying NDIA source data and methodology not independently verified; detail behind paywall |
| R4-15 | Referral pathway for new providers | Support Coordinators are primary referral gatekeepers; speed/low-friction intake wins referrals | https://astalty.com.au/articles/how-to-get-more-referrals-as-a-new-provider | Astalty (practitioner blog) | undated | 2026-08-20 | Low | Single anecdotal practitioner blog post, not a data-backed industry study |
| R4-16 | SIL/SDA compliance and registration tightening (flagged, not detailed) | NDS published guidance exists on this topic | https://nds.org.au/news/looking-ahead-at-sil-and-sda-compliance-and-registration | NDS | undated | 2026-08-20 | Low | Identified via search only; content not fetched, so specific claims within it are unverified |

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## UNVERIFIED / COULD NOT CONFIRM

- Current (2026) Victoria-specific count of registered and active NDIS providers, and any Victoria-specific measure of provider concentration or "thin markets."
- A definitive statement, from an authoritative source, that metropolitan Melbourne core supports are currently over- or under-supplied.
- An aggregate NDIS-sector insolvency or business-exit rate from ASIC or another registrar (only illustrative named examples were found: Centacare Queensland, Bedford Group, NDISP).
- Quantified, near-term (FY2026-27) impact of foundational supports/Thriving Kids on core-supports demand volumes.
- Plan management market concentration/consolidation data (HHI, top-N share, provider count trend) and confirmation of any formal (as opposed to anticipated) policy change specific to plan management.
- SDA design-category-level demand/vacancy breakdown, and Victoria/Melbourne-specific SDA utilisation (only a national aggregate was accessible).
- Detail behind the NDS "Looking ahead at SIL and SDA compliance and registration" guidance (page identified but not fetched).
- Any quantified industry benchmark for typical "time to first client" for a new NDIS provider, in any of the three models.
- The role of plan managers and provider-finder/marketplace listings (e.g. NDIS "Provider Finder", Clickability, myCareBase-type platforms) in generating first clients — no data located.
- Whether the September 2025 CSV-based national "277,376 active providers" figure (R4-04) and the "269,000+ providers" industry-report figure (R4-05) refer to the same population/definition — the two were not reconciled.